Saturday, October 2, 2010

Verification Body Information

The value of relying on a national accreditation body such as ANAB was acknowledged in the
DOE final rule at 10 CFR 300.11(c) “Qualifications of organizations accrediting verifiers.” That
paragraph reads as follows: “Organizations that accredit individual verifiers must be nationally
recognized certification programs. They may include, but are not limited to the: American
Institute of Certified Public Accountants; American National Standards Institute’s Registrar
Accreditation Board program for Environmental Management System auditors (ANSI–RAB–
EMS); Board of Environmental, Health and Safety Auditor Certification: California Climate
Action Registry; Clean Development Mechanism Executive Board; and the United Kingdom
Accreditation Scheme.”

The value of relying on a national accreditation body such as ANAB was acknowledged in the
DOE final rule at 10 CFR 300.11(c) “Qualifications of organizations accrediting verifiers.” That
paragraph reads as follows: “Organizations that accredit individual verifiers must be nationally
recognized certification programs. They may include, but are not limited to the: American
Institute of Certified Public Accountants; American National Standards Institute’s Registrar
Accreditation Board program for Environmental Management System auditors (ANSI–RAB–
EMS); Board of Environmental, Health and Safety Auditor Certification: California Climate
Action Registry; Clean Development Mechanism Executive Board; and the United Kingdom
Accreditation Scheme.”

Proposed Changes
We propose to change xx-10.6(a) to read as follows:
Standards for Accreditation. Verification Bodies may be accredited by the REGULATORY
AGENCY or its agent in accordance with the requirements of this section. Verification bodies
that are accredited by the ANSI-ASQ National Accreditation Board or other approved national
accreditation bodies shall be deemed accredited by the REGULATORY AGENCY or its agent.
We propose to substitute the following language for the text that currently exists at xx-
10.6(a)(1):
Scope of verification. Independent verifications shall be conducted using recognized
guidance documents such as “Attest Engagements on Greenhouse Gas Emissions
Information” published by the American Institute of Certified Public Accountants”
(Statement of Position 03-2 issued under the authority of the Auditing Standards Board,
September 22, 2003) or International Standards such as ISO 14064:2006 “Greenhouse
gases – Part 3: Specification with guidance for the validation and verification of
greenhouse gas assertions” (published by the International Organization for
Standardization). Verification body auditors shall use their expertise and professional
judgment to verify to a specified level of assurance the accuracy, completeness and
consistency with Model Rule guidelines of:
(1) Assertions relevant to CO2 Emissions Offsets made by a project sponsor;
(2) The procedures and methods used by the project sponsor to calculate, monitor and
report emissions reductions;
(4) Relevant personnel training and management systems; and
(5) Relevant quality assurance/quality control procedures.
We propose to add a new xx-10.6(a)(2) to read as follows:
Verification statement. The verification body shall appoint competent personnel different
from those who performed the verification to review the verification statement. The
verification statement shall be signed and issued in accordance with the verification body’s
procedures. The verification statement shall include the following:
a) name, address and other relevant contact information for the project sponsor and/or the client;
b) a statement that the verification is performed according to ISO 14064 Part 3 or to AICPA
“Attest Engagements on Greenhouse Gas Emissions Information”;
c) an opening or introductory paragraph containing
1)identification of the project sponsor's GHG assertion against which the
verification testing was conducted, and
2)a statement of the roles and responsibilities of the project sponsor's
management and the roles and responsibilities of the verifier;
2006-05-22
Page 5 of 6
NSF-ISR Comments on the Model Rule to the RGGI Staff Working Group
d) a scope paragraph containing
1)
reference to the principles and requirements of applicable regulations against
which the verification was conducted,
2)
reference to the verification scope, objectives and criteria agreed with the
client, including the level of assurance required, and
3)
a description of the work the verification team performed, including the
techniques and processes used to test the GHG information and associated
GHG assertion;
e) a conclusion paragraph containing
1)
a reference to the regulatory requirements used to prepare the GHG
assertion,
2)
GHG information or performance verified (e.g. project plan, baseline GHG
emissions or removals, GHG emissions, removals, emission reductions, removal
enhancements),
3)
the level of assurance provided by the verification, consistent with the agreed
verification scope, objectives and criteria,
4)
presentation of qualifications, if any, and
5)
conclusions on the GHG assertion, including any limitations or qualifications to
the conclusion;
f) the date of the verification statement;
g) the verifier contact details;
h) an authorized signature from the verifier.
Conclusion
We thank the Staff Working Group for its consideration of our comments, and remain available
to answer any questions that may arise.
Sincerely yours,
John C. Shideler, PhD
Greenhouse Gas Program Manager